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TTB Public Guidance

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October 27, 2017
TTB G 2016-1A

Beers and Malt Beverages that Require Either Formula Approval or
Formula Approval with Laboratory Sample Analysis

The following charts list the types of beers and malt beverages that require formula approval or formula approval with laboratory sample analysis prior to applying for a certificate of label approval, or COLA (if label approval by TTB is required).  In the case of domestic beers, brewers generally must obtain formula approval before beginning production.

If you do not see a product listed here, then formula approval and laboratory sample analysis is not generally required.  However, TTB may request submission of a formula or samples for laboratory analysis on a case-by-case basis for any alcohol beverage product, even though no such requirement is indicated in the charts.

These charts are updated from time to time as TTB policy changes. The date of the most recent revision is listed at the bottom of the page.

For more information about formulas, laboratory sample analysis, and how to apply for approval, visit our Alcohol Beverage Formula Approval page.   

Formula approval or formula approval with laboratory sample analysis is typically required for the following products:

Product

Domestic

Imported*

Formula Approval Only

Formula Approval and Laboratory Sample Analysis

Formula Approval Only

Formula Approval and Laboratory Sample Analysis

Alcohol Free Malt Beverage (0.0 percent alcohol by volume)

 

 

Ice Beer

 

 

Kombucha*

 

 

 

Saké**

 

 

Saké with added colors or flavors**

 

 

Malt beverage specialty products (such as flavored beer)  (unless exempted by TTB Ruling 2015-1)***

 

 

*Formula requirements for imported products generally apply only if the product is classified as a malt beverage (or wine or distilled spirit) under the FAA Act and requires a COLA. 

**Imported Saké requires a formula as a wine under the FAA Act when it contains at least 7 percent alcohol by volume. 

***See Attachment 1 to TTB Ruling 2015-1 to determine which flavors or ingredients have been determined by TTB to be traditional in the production of malt beverages and are exempt from formula requirements. If you use an ingredient that has not been determined to be traditional (i.e., it is nontraditional) then formula approval is required. TTB Ruling 2015-1  applies ONLY to malt beverages under the FAA Act (i.e., products that are made from both malted barley and hops) that meet the requirements outlined in the ruling. 

Formula approval is always required if the brewer uses the following processes to make a beer/malt beverage.

Process

Formula Approval

Domestic

Imported*

Removal of any volume of water (for example, by freezing)

Filtration in order to substantially change the color, flavor, or character

Separation into different components

Reverse osmosis (on the product itself, not on ingredients used in the product, such as water)

Concentration (production of beer concentrate)

Ion exchange treatments

 

Any other process or treatment not listed above that substantially changes the color, flavor, or character**

*Formula requirements for imported products generally apply only if the product is classified as a malt beverage (or wine or distilled spirit) under the FAA Act and requires a COLA. 

**See Attachment 1 to TTB Ruling 2015-1 to determine which processes have been determined by TTB to be traditional in the production of malt beverages and thus exempt from formula requirements.  TTB Ruling 2015-1 applies ONLY to malt beverages under the FAA Act (i.e., products that are made from both malted barley and hops) that meet the requirements outlined in the ruling.

Formula approval or formula approval with laboratory sample analysis is required if the brewer uses the following ingredients to make a beer/malt beverage.

Ingredient

Domestic

Imported*

Formula Approval Only

Formula Approval and Laboratory Sample Analysis

Formula Approval Only

Formula Approval and Laboratory Sample Analysis

Extracts (other than hops extract)

 

 

Essential Oils

 

 

Syrups

 

 

Flavors that contain alcohol

 

 

Natural or artificial flavors (unless exempt)**

 

 

Compounded flavors

 

 

Coloring (unless exempt)**

 

 

Artificial sweeteners

 

 

Any ingredient that typically contains thujone (for example, wormwood, tansy, or yarrow)

 

 

Hemp or hemp component

 

 

Nontraditional ingredient**

 

 

*Formula requirements for imported products generally apply only if the product is classified as a malt beverage (or wine or distilled spirit) under the FAA Act and requires a COLA. 

**See Attachment 1 to TTB Ruling 2015-1 to determine which flavors or ingredients have been determined by TTB to be traditional in the production of malt beverages and are exempt from formula requirements. If you use an ingredient that has not been determined to be traditional (i.e., it is nontraditional) then formula approval is required.  TTB Ruling 2015-1 applies ONLY to malt beverages under the FAA Act (i.e., products that are made from both malted barley and hops) that meet the requirements outlined in the ruling.

Page last reviewed: September 5, 2017
Page last updated: October 31, 2017
Maintained by: Alcohol Labeling and Formulation Division, Regulations and Rulings Division

TTB G: 2016-1A
OPR: ALFD
Last updated:

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